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Vosaic Privacy Statement

Effective Date: 02/28/2023

Vosaic (“we,” “us,” or “our”) an affiliate of Nelnet, operates the website https://vosaic.com (the “Website”), which is governed by this Privacy Policy (the "Policy"). We respect your privacy and are committed to protecting the personal information that you provide to us. We intend to use such information for purposes of supporting your relationship with us by designing website content that is suitable to your needs and alerting you to new product and service offerings as they become available.

This Policy applies to any individual or entity (“you”, “your”, or “User”) who uses the Website. This Policy is designed to inform you of the types of information we collect from users, how we use that information, and the circumstances under which we will share it with third parties when users utilize the products and services (collectively, the "Services"). This Policy pertains to information collected only directly through the Website and does not apply to personal information collected from offline resources and communications (for instance, if you send us a postal letter or call us).

By using the Website, you consent to the collection and use of your personal information by Vosaic. If you do not agree to the terms herein please do not use the Website.

Changes To Our Policy

To ensure accuracy and security, we reserve the right to review and update this Policy from time to time as needed, without prior notice. If any material changes or modifications are made, we will update the “Effective Date” heading appearing at the top of this web page and provide notice via email or web banner. Such changes or modifications shall be effective immediately upon posting to the Website, and supersede any prior versions of this Policy. Therefore, you should review the terms of this Policy periodically to make sure that you are aware of how we collect and use personal information.

Types of Information Collected

NON-IDENTIFYING INFORMATION

We, and/or our third-party advertising or technology vendors, may collect Non-Personally Identifiable Information using various tracking technologies described in this Policy. Non-Personally Identifiable Information is anonymous and includes information such as IP address, web pages which have been viewed, location, search queries that have been submitted, date and time, domain type, and responses by a visitor to an advertisement and content delivered by us or a third party advertising or technology vendor. We may use different types of technologies to collect this type of information, including cookies and web beacons (1×1 pixels). Additionally, when requesting further information on the Website, we may collect additional Non-Personally Identifiable Information about the individual. Examples of Non-Personally Identifiable Information that may be requested include geographic location. None of this Non-Personally Identifiable Information, by itself, or together with other Non-Personally Identifiable Information, can by its nature be matched with a specific individual.

PERSONALLY IDENTIFIABLE INFORMATION

Personally Identifiable Information, as used in this Policy, means any information or set of information that identifies a specific individual, and may be collected, for example, when users request more information or contribute to a chat, or in any other way submit personal information to us via the Website. Examples of Personally Identifiable Information that may be requested include your first and last name, email address, company name, and phone number(s). We collect this information on the Website to provide you with information in the form of e-mails, to allow you to request information from us, and otherwise correspond with you about our Services. You can choose not to provide your Personally Identifiable Information by electing not to complete a form. By providing your personal information, you acknowledge and consent to our use of your Personally Identifiable Information in accordance with this Policy.

How We Collect Information

We automatically collect certain Non-Personally Identifiable Information on the Website through cookies, web beacons, log files, and other common website data collection techniques.

When you enter the Website, we will identify the Internet Protocol (IP) address of your computer or handheld device. The IP address does not identify you personally, but it lets us identify the device you are using. We store IP addresses in case we need to track a connection for security purposes. We may also collect information about the device you are using to access Administrator Services, including what type of device it is, what operating system you are using, device settings, unique device identifiers, geo-location data, and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. Check the policies of your device manufacturer or software provider to learn more about what information your device makes available to us.

WEBSITE COOKIES

The Website may place “cookies” on a visitor’s computer. Cookies are small text files saved on your hard drive. Our cookies save anonymized (e.g. Non-Personally Identifiable) data about individual visitors, allowing the website to recognize information about a visitor and help deliver personalized content and other services and functions. The Website may use both session cookies, which terminate when a User closes his or her browser, and persistent cookies, which remain on the User’s computer until they expire or are manually deleted. A cookie does not retrieve any other data from your hard drive.

The Website may also contain coding from our third party business and technology partners, which generate third-party cookies. Third-party cookies allow these third party business and technology partners to store Non-Personally Identifiable Information, which is accessible when you visit the Website or other third party website. We do not control use of these cookies.

Most browsers allow you to control cookies, including whether or not to accept them, and provide the ability to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Blocking cookies may result in a lower quality experience for you while you are using the Website, or otherwise stop certain features on the Website from functioning. Blocking cookies does stop all tracking activities described in this Policy.

WEB BEACONS (1x1 PIXELS OR GIFS)

Our Website contain coding known as Web Beacons that use 1×1 pixel images to capture and transmit the online activity of users on the Website. These Web Beacons typically transmit information about the completion of forms on the Website and other website activities in order to measure advertising effectiveness and/or store analytics information. In addition, we may use Web Beacons in HTML-based emails. This use allows us to evaluate the effectiveness of our email communications and our marketing campaigns by showing how many emails recipients open.

LOG FILES

Like most websites, our servers utilize log files. Log files store information including internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. Log files are used to analyze trends, administer the Website, track Users’ movement in the aggregate, and gather broad demographic information for aggregate use. We use log file information at times to help identify you as you browse and to gather broad technical and demographic information on who uses our Website.

GOOGLE ANALYTICS ADVERTISING FEATURES

We may use Google Analytics to collect information about the use of the Website. Google Analytics collects information such as how often users visit the Website, what pages they visit when they do so, and what other sites they used prior to coming to the Website. We use the information we get from Google Analytics only to improve the Website. Google Analytics collects only the IP address assigned to you on the date you visit the Website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with Personally Identifiable Information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this Website by disabling the Google Analytics cookie on your browser. You can also view and change the currently available opt-outs for Google Ads.

We also use the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to of our Website. This could be in the form of an advertisements on other website or on the Google search results page. Third party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Website. Any data collection will be used in accordance with our own Policy and Google’s privacy policy. You can set preferences for how Google advertises to you using Google’s Ads Settings. Alternatively, you can opt-out of a third party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.

DO NOT TRACK SIGNALS

Do Not Track is a feature in your web browser, which enables you to opt-out of the third party tracking of your online activities over time and across third party websites. We do not process or comply with any web browser’s “do not track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit the Website or use our Services. Third parties cannot collect any Personally Identifiable Information from the Website unless you provide it to them directly.

INFORMATION YOU PROVIDE TO US

In addition to the information collected automatically, we also collect information that you provide to us when you request information about Vosaic, when you register for a webinar, when you download content from our Website or when you take any other action to otherwise voluntarily provide information about yourself or your company. Our information request pages require users to provide us with contact information (name, phone number, email address, etc.).

TESTIMONIALS

From time to time, we may post customer testimonials/comments/reviews on the Website, which may contain Personally Identifiable Information. If the testimonial will include the User's name or information identifying the company, we do obtain the customer’s consent via email prior to posting the testimonial.

How We Use and Share Information

The information you provide to us and automatically-collected information (both Personally and Non-Personally Identifiable Information) is used to provide a number of different functions and services on the Website and to provide an enhanced online experience for users. We collect information so we can identify you as our customer, to establish to offer you Services you might be interested in, to personalize and improve upon your experience with us, and to comply with various legal and regulatory requirements.

Third-party advertising companies may also be utilized by us to target display advertising to you once you leave the Website. These companies may use Non-Personally Identifiable Information about your visits to the Website in order to provide advertisements about goods and services that may be of interest to you. It is solely your obligation to review and understand the privacy practices and policies of these advertisers and their associated third parties. These advertisers and their associated third parties are independent entities over which we exercise no control. We are not responsible for, and will not be liable for, their conduct, actions, omissions, or information handling or dissemination practices. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

SHARING OF INFORMATION

We do not sell, trade or transfer user information to third parties, except under the circumstances described below, or as otherwise provided in this Policy, or required or permitted by law. You may separately agree to provide your personal information to third parties that provide content for us, in order to use their products and/or services. If you agree to provide information to these third parties, then your personal information will be subject to their privacy policies. If you decide that we should not use your personal user information to contact you, please inform us of your decision by using the information in the contact us page, and we will not use that information for such purpose.

  • To verify compliance with the agreement between us and yourself.
  • If you give us your consent, we may share your Personally Identifiable Information with third parties pursuant to the terms of your consent.
  • We aggregate information into statistics about Users, including their usage of the Website, traffic patterns, and demographics. We may provide third parties with such statistics, but such information does not constitute Personally Identifiable Information.
  • We may occasionally share your information with our affiliates, service providers, and other third parties that help to operate our business and this Website and deliver the Services available on or through the Website to: facilitate, improve, or outsource elements of our service or operation of the Website, including processing transactions, sending emails, and providing marketing assistance or analysis.
  • We may provide your information to, or exchange your information with, these service providers for use in their provision of services to us, such as fraud protection, compliance monitoring, or marketing analysis. These external service providers may have access to Personally Identifiable Information needed to perform their functions or services to us, but may not use it for other purposes including their own marketing.
  • We may sell, transfer or otherwise share some or all of our assets, including your Personally Identifiable Information, in connection with a merger, acquisitions, reorganization or sale of assets including in the event of bankruptcy.

In addition to the uses described above, sometimes the law or other circumstances require that we disclose Personally Identifiable Information about you to nonaffiliated third parties. Some examples are the following:

  • To assist law enforcement or other governmental agencies investigating cases of possible illegal activities by third parties.
  • To respond to subpoenas, court orders, legal process, and to establish or exercise our legal rights to defend against legal claims.
  • To enforce or apply our agreements, and to protect the rights, property, or safety of our users or others.
  • To prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.
  • To improve the experience and functionality of the Website, to improve our Services, to improve marketing and promotion of our Services, to customize the Website’ content and layout, and generally to improve the Website to meet your needs better.

E-mail Opt Out Policy

By providing your email address through the Website, you consent that we may send email to you regarding our Services. You can choose to opt out of receiving email communications from us by following the unsubscribe instructions in the email communication you receive from us or by contacting us directly using the information in the "Contact Us" section below.

In accordance with this Policy, we may have shared your email address with third parties. When that occurs, we no longer have direct control over the use of such information, and your rights regarding such use will be governed by such third party's policies. You will have to contact them directly with any email opt-out request.

Security Measures to Protect your Information

We have implemented reasonable and appropriate physical, procedural, and electronic safeguards to protect your information from unauthorized access and improper use. We review our security procedures on a regular basis to consider new or updated and appropriate technology and methods. Please be aware, however, that no method of transmission of information over the Internet, or method of electronic storage of information, is 100% secure. Therefore, while we strive to use reasonable and appropriate means to protect your information, we cannot guarantee its absolute security. If you have any questions about security on our Website, you can send email us using the information provided in the "Contact Us" section, below.

Children’s Privacy (COPPA), FERPA and HIPAA

The Website is not directed to children under 13. We do not knowingly collect, maintain, or use information from children under age 13. If a parent or guardian becomes aware that his or her child has provided us with Personally Identifiable Information without their consent, he or she should contact us using the information in the "Contact Us" section, below. If we confirm we have collected such information, we will take all reasonable measures to delete that information from our system as soon as possible.

Vosaic complies with the Family Educational Rights and Privacy Act ("FERPA"). Some of the personal information that we collect from customers through our products and services may be subject to FERPA. We will keep this personal information confidential and only use this data to offer our products and services in accordance with this Policy and our Terms of Use, or for other lawful purposes. Additionally, we will not use FERPA-protected information to market new products or services, to target students with directed advertisements, or sell the information to a third party.

Vosaic does not knowingly collect Protected Health Information (PHI), as PHI is not required for use of Vosaic’s services. In the event that PHI is included in data uploaded in connection with Vosaic’s services, such data will be handled in accordance with Amazon Web Service’s HIPAA Compliance Policy. Amazon will notify Vosaic in the event of a breach of security in its environment, and Vosaic will notify the owner of the data as soon as practicable.

Student account information is private in the system, viewable only by authorized instructors and IT administrators. Students must explicitly grant viewing permissions within Vosaic.

Authorized Vosaic staff may access the account information solely for the purpose of providing service and support to the instructor and students. Such access is limited to authorized service and support staff only. Consent for this is limited to use of their information is granted by each user upon signup with required acceptance of the user terms.

While the Website provide links to other website, this Policy applies only to our Website. It does not apply to your use of any other website (whether or not operated by us), including any website to which we provide links or website of our business partners. Even if the third party is affiliated with Vosaic and/or Nelnet through a business partnership or otherwise, we are not responsible for the privacy policies or practices or the content of such external links. Your browsing and interaction on any third party website or service are subject to that third party's own rules and policies. We are not responsible for, and will not be liable for such third parties' conduct, actions, omissions, or information handling or dissemination practices. These links are provided to you for convenience purposes only and you access them at your own risk.

Contact Details for Privacy and Data-related Inquiries

Data Controller:

Contact Your Educational Institution or Merchant

Data Processor:

Nelnet, Inc.
Chief Compliance Officer
AskPrivacy@Nelnet.net
402-323-4979